Giallanzo Et Al.

AL:NMA:LKG/KDE
F.#2017R00410
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK
-X
UNITED STATES OF AMERICA
- against - Cr.
(T. 1 , U.S.C., 892(a), 893, 894(a),

RONALD GIALLANZO, 894(a)(l), 981(a)(l)(C), 1512(c)(2),
also known as "Ronnie G," 1512(k), 1623, 1955, 1955(d), 1962(d),
MICHAEL PADAVONA, 1963, 1963(a), 1963(m), 2 and 3551 et~.;
also known as "Mike," T. 21, U.S.C., 853(p); T. 28, U.S.C.,
MICHAEL PALMACCIO, 2461(c))
also known as "Mike,"

NICHOLAS FESTA,
also known as "Pudgie,"
CHRISTOPHER BOOTHBY, GARAUFIS, J.
also known as "Bald Chris,"
EVAN GREENBERG,
also known as "The Jew,"
RICHARD HECK,
also known as "Richie,"
MICHAEL HINTZE,
also known as "Mike,"
ROBERT PISANI,
also known as "Rob," and
ROBERT TANICO,
also known as "Chippy" and "Chip,"
Defendants.
-X
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THE GRAND JURY CHARGES:
INTRODUCTION
At all times relevant to this Indictment, unless otherwise indicated:
The Enterprise
1. The Bonanno organized crime family of La Cosa Nostra, including its
leaders, members and associates (the "Bonanno family"), constituted an "enterprise," as
defined in Title 18, United States Code, Section 1961(4), that is, a group of individuals
associated in fact. The Bonanno family engaged in, and its activities affected, interstate and
foreign commerce. The Bonanno family was an organized criminal group that operated in
the Eastern District of New York, other parts of the United States and Canada. The
Bonanno family constituted an ongoing organization, whose members functioned as a
continuing unit for a common purpose of achieving the objectives of the enterprise.
2. The Bonanno family operated through groups of individuals headed by
"captains," who were also referred to as "skippers," "caporegimes" and "capodecinas."
These groups, which were referred to as "crews," "regimes" and "decinas," consisted of
"made" members of the Bonanno family, also referred to as "soldiers," "friends of ours,"
"good fellows" and "buttons," as well as associates of the Bonanno family.
3. Each captain was responsible for supervising the criminal activities of
his crew and providing crew members and associates with support and protection. In return,
the captain received a share of the earnings of each of the crew's members and associates.
4. Above the captains were the three highest-ranking members of the
Bonanno family. The head of the Bonanno family was known as the "boss." He was
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assisted by an "underboss" and a counselor, who was known as the "consigliere." With the
assistance of the underboss and consigliere, the boss was responsible for setting policy,
resolving disputes between members and associates of the Bonanno family and members and
associates of other criminal organizations, and approving all significant actions taken by
members and associates of the Bonanno family, including murder.
5. The boss, underboss and consigliere of the Bonanno family, who were
sometimes refe1red to collectively as the "administration," supervised, supported, protected
and disciplined the captains, soldiers and associates and regularly received reports regarding
the activities of the members and associates of the Bonanno family. In return for their
supervision and protection, the boss, underboss and consigliere received part of the illegal
earnings of each crew.
6. The Bonanno family was part of an international criminal organization
known by various names, including the "mafia" and "La Cosa Nostra," which operated
through entities known as "families." The ruling body of this organization was known as
the "commission," the membership of which at various times has included the bosses of the
five New York City-based families, to wit: the Bonanno, Colombo, Gambino, Genovese and
Luchese organized crime families. For a period of time, the boss of the Bonanno family was
removed from membership within the commission.
7. From time to time, the Bonanno family would propose a list of
associates to be "made," that is, to become members of the Bonanno family. The list would
be circulated to the other families based in New York City. Upon becoming "made," each
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member would take an oath of "omerta," vowing never to reveal any information about the
Bonanno family, its members or associates.
The Purposes, Methods and Means of the Enterprise
8. The principal purpose of the Bonanno family was to generate money
for its members and associates. This purpose was implemented by members and associates
of the Bonanno family through various criminal activities, including drug trafficking,
extortion, illegal gambling, loansharking, and robbery. The members and associates of the
Bonanno family also furthered the enterprise's criminal activities by threatening economic
injury and using and threatening to use physical violence, including murder.
9. Although the primary purpose of the Bonanno family was to generate
money for its members and associates, the members and associates at times used the
resources of the Bonanno family to settle personal grievances and vendettas, sometimes with
the approval of higher-ranking members of the Bonanno family. For those purposes,
members and associates of the enterprise were asked and expected to carry out, among other
crimes, acts of violence, including murder, assault and arson.
10. The members and associates of the Bonanno family engaged in conduct
designed to prevent government detection of their identities, their illegal activities and the
location of proceeds of those activities. That conduct included a commitment to murdering
persons, particularly members or associates of organized crime families, who were perceived
as potential witnesses against members and associates of the enterprise.

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11. Members and associates of the Bonanno family often coordinated
street-level criminal activity, such as drng trafficking, illegal gambling, loansharking,
extortion and robbery, with members and associates of other organized crime families.
The Defendants
12. At all times relevant to this Indictment, the defendant RONALD
GIALLANZO, also known as "Ronnie G," was a soldier and acting captain in the Bonanno
family.
13. At various times relevant to this Indictment, the defendant MICHAEL
PADAVONA, also known as "Mike," MICHAEL PALMACCIO, also known as "Mike,"
and NICHOLAS FESTA, also known as "Pudgie," were associates and soldiers in the
Bonanno family.
14. At various times relevant to this Indictment, the defendants
CHRISTOPHER BOOTHBY, also known as "Bald Chris," EVAN GREENBERG, also
known as "The Jew," RICHARD HECK, also known as "Richie," MICHAEL HINTZE, also
known as "Mike," ROBERT PISANI, also known as "Rob," and ROBERT TANICO, also
known as "Chippy" and "Chip," were associates in the Bonanno family.
COUNT ONE
(Racketeering Conspiracy)
15. The allegations in paragraphs one through 14 are realleged and
incorporated as if fully set forth in this paragraph.
16. On or about and between January 1, 1998 and the date of this
Indictment, both dates being approximate and inclusive, within the Eastern District of New
York and elsewhere, the defendants RONALD GIALLANZO, also known as "Ronnie G,"
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MICHAEL PADAVONA, also known as "Mike," MICHAEL PALMACCI0, also known as
"Mike," NICHOLAS FESTA, also known as "Pudgie," CHRISTOPHER BOOTHBY, also
known as "Bald Chris," EVAN GREENBERG, also known as "The Jew," RICHARD
HECK, also known as "Richie," MICHAEL HINTZE, also known as "Mike," ROBERT
PISANI, also known as "Rob," and ROBERT TANICO, also known as "Chippy" and
"Chip," together with others, being persons employed by and associated with the Bonanno
family, an enterprise that engaged in, and the activities of which affected, interstate and
foreign commerce, did knowingly and intentionally conspire to violate Title 18, United
States Code, Section 1962(c), that is, to conduct and participate, directly and indirectly, in
the conduct of the affairs of that enterprise through a pattern of racketeering activity, as
defined in Title 18, United States Code, Sections 1961(1) and 1961(5), consisting of the
racketeering acts set forth below. Each defendant agreed that a conspirator would commit at
least two acts of racketeering in the conduct of the affairs of the enterprise.
RACKETEERING ACT ONE
(Kidnapping Conspiracy/Kidnapping/Robbery Conspiracy/
Attempted Robbery-John Doe #1)
17. The defendant CHRISTOHER BOOTHBY agreed to the commission
of the following acts, any one of which alone constitutes Racketeering Act One:
A. Kidnapping Conspiracy
18. On or about Febrnary 2, 1998, within the Eastern District of New York,
the defendant CHRISTOPHER BOOTHBY, together with others, did knowingly and
intentionally conspire to kidnap John Doe #1, in violation of New York Penal Law Sections
135.20 and 105.10.

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19. In furtherance of the conspiracy and to effect its objects, within the
Eastern District of New York, the defendant CHRISTOPHER BOOTHBY, together with
others, did commit and cause to be committed, among others, the following:
Overt Acts
a. On or about February 2, 1998, the defendant CHRISTOPHER
BOOTHBY and a co-conspirator attempted an armed robbery of John Doe #1; and
b. On or about February 2, 1998, the defendant CHRISTOPHER
BOOTHBY and a co-conspirator tied up John Doe #1.
B. Kidnapping
20. On or about February 2, 1998, within the Eastern District of New York,
intentionally kidnap John Doe #1, in violation of New York Penal Law Sections 135.20 and
20.00.
C. Robbery Conspiracy
intentionally conspire to forcibly steal property, to wit: money from John Doe # 1, while
aided by another person actually present, in violation of New York Penal Law Sections
160.10 and 105.10.
22. In fu1iherance of the conspiracy and to effect its objects, within the
Eastern District of New York, the defendant CHRISTOPHER BOOTHBY, together with
others, did commit and cause to be committed, among others, the following:
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Overt Acts
a. On or about February 2, 1998, the defendant CHRISTOPHER
BOOTHBY and a co-conspirator attempted an aimed robbery of John Doe #1; and
b. On or about February 2, 1998, the defendant CHRISTOPHER
BOOTHBY and a co-conspirator tied up John Doe #1.
D. Attempted Robbery
intentionally attempt to forcibly steal property, to wit: money from John Doe #1, in violation
of New York Penal Law Sections 160.05, 110.05 and 20.00.
RACKETEERING ACT TWO
(Extortionate Extension and Collection of Credit Conspiracy)
24. The defendants RONALD GIALLANZO, MICHAEL PADAVONA,
MICHAEL PALMACCIO, NICHOLAS FESTA, RICHARD HECK and MICHAEL
HINTZE agreed to the commission of the following acts, either one of which alone
constitutes Racketeering Act Two:
A. Extortionate Extension of Credit Conspiracy
York and elsewhere, the defendants RONALD GIALLANZO, MICHAEL PADAVONA,
HINTZE, together with others, did knowingly and intentionally conspire to make one or
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more extortionate extensions of credit, in violation of Title 18, United States Code, Section
892(a).
B. Extortionate Collection of Credit Conspiracy
York and elsewhere, the defendants RONALD GIALLANZO, MICHAEL PADAVONA,
HINTZE, together with others, did knowingly and intentionally conspire to participate in the
use of extortionate means (1) to collect and attempt to collect one or more extensions of
credit and (2) to punish one or more persons for the nonrepayment thereof, in violation of
Title 18, United States Code, Section 894(a).
RACKETEERING ACT THREE

(Ext01iion Conspiracy/Extortion- John Doe #2 and John Doe #3)
27. The defendant MICHAEL PALMACCIO agreed to the commission of
the following acts, either one of which alone constitutes Racketeering Act Three:
A. Extortion Conspiracy
28. On or about and between January 1, 2000 and December 31, 2001, both
dates being approximate and inclusive, within the Eastern District of New York and
elsewhere, the defendant MICHAEL PALMACCI0, together with others, did knowingly and
intentionally conspire to steal property by exto1iion, in that the defendant and others agreed
to obtain property, to wit: money, by compelling and inducing John Doe #2 and John Doe
#3, individuals whose identities are known to the Grand Jury, to deliver such property by
instilling in John Doe #2 and John Doe #3 a fear that if the property were not so delivered,
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one or more persons would cause physical injury to some person in the future and cause
damage to property, in violation of New York Penal Law Sections 155.40(2), 155.05(2)(e)(i),
155.05(2)(e)(ii) and 105.10.
29. In fu1iherance of the conspiracy and to effect its objects, within the
Eastern District of New York and elsewhere, the defendant MICHAEL PALMA CCI 0,
together with others, did commit and cause to be committed, among others, the following:
Ove1iActs
a. On or about October 15, 2000, the defendant MICHAEL
PALMACCIO and a co-conspirator went to the office of John Doe #2 and John Doe #3; and
b. On or about October 15, 2000, the defendant MICHAEL
PALMACCIO assaulted John Doe #2 at the office of John Doe #2 and John Doe #3.
B. Ext01iion
elsewhere, the defendant MICHAEL PALMACCIO, together with others, did knowingly and
intentionally steal property by extortion, in that the defendant and others obtained prope1iy,
to wit: money, by compelling and inducing John Doe #2 and John Doe #3 to deliver such
property by instilling in John Doe #2 and John Doe #3 a fear that if the property were not so
delivered, one or more persons would cause physical injury to some person in the future and
cause damage to property, in violation of New York Penal Law Sections 155.40(2),
155.05(2)(e)(i), 155.05(2)(e)(ii) and20.00.

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RACKETEERING ACT FOUR

(Extortionate Extension and Collection of Credit- John Doe #4)
31. The defendants RONALD GIALLANZO and MICHAEL
PALMACCIO agreed to the commission of the following acts, either one of which alone
constitutes Racketeering Act Four:
A. Extortionate Extension of Credit
32. On or about and between January 1, 2001 and November 30, 2015,
both dates being approximate and inclusive, within the Eastern District of New York and
elsewhere, the defendants RONALD GIALLANZO and MICHAEL PALMACCIO, together
with others, did knowingly and intentionally make one or more extortionate extensions of
credit to John Doe #4, an individual whose identity is known to the Grand Jury, in violation
of Title 18, United States Code, Sections 892(a) and 2.
B. Extortionate Collection of Credit
elsewhere, the defendants RONALD GIALLANZO and MICHAEL PALMACCIO, together
with others, did knowingly and intentionally paiiicipate in the use of extortionate means
(1) to collect and attempt to collect one or more extensions of credit from John Doe #4, and
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(2) to punish John Doe #4 for the nonrepayment thereof, in violation of Title 18, United
States Code, Sections 894(a) and 2.
RACKETEERING ACT FIVE

(Narcotics Distribution Conspiracy- Cocaine and Hydrocodone)
34. On or about and between January 1, 2001 and February 28, 2014, both
elsewhere, the defendant MICHAEL PALMACCIO, together with others, did knowingly and
intentionally conspire to distribute and possess with intent to distribute one or more
controlled substances, which offense involved (a) a substance containing cocaine, a Schedule
II controlled substance; and (b) a substance containing hydrocodone, a Schedule II controlled
substance, in violation of Title 21, United States Code, Sections 846 and 841 (b)( 1)(C).
RACKETEERING ACT SIX

(Narcotics Distribution Conspiracy- Cocaine and Hydrocodone)
35. On or about and between January 1, 2003 and February 28, 2014, both
elsewhere, the defendant NICHOLAS FESTA, together with others, did knowingly and
intentionally conspire to distribute and possess with intent to distribute one or more
controlled substances, which offense involved (a) a substance containing cocaine, a Schedule
II controlled substance; and (b) a substance containing hydrocodone, a Schedule II controlled
substance, in violation of Title 21, United States Code, Sections 846 and 84l(b)(l)(C).
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RACKETEERING ACT SEVEN

(Extortionate Extension and Collection of Credit - Jane Doe # 1)
PADAVONA agreed to the commission of the following acts, either one of which alone
constitutes Racketeering Act Seven:
37. On or about and between July 1, 2004 and July 1, 2006, both dates
being approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendants RONALD GIALLANZO and MICHAEL PADAVONA, together with others, did
knowingly and intentionally make one or more extortionate extensions of credit to Jane Doe
#1, an individual whose identity is known to the Grand Jury, in violation of Title 18, United
38. On or about and between July 1, 2004 and July 1, 2006, both dates
knowingly and intentionally participate in the use of extortionate means (1) to collect and
attempt to collect one or more extensions of credit from Jane Doe #1, and (2) to punish Jane
Doe #1 for the nonrepayment thereof, in violation of Title 18, United States Code, Sections
894(a) and 2.
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RACKETEERING ACT EIGHT
(Extortionate Extension and Collection of Credit - Jane Doe #2)
the following acts, either one of which alone constitutes Racketeering Act Eight:
40. On or about and between September 1, 2004 and September 1, 2005,
elsewhere, the defendant MICHAEL PALMACCI 0, together with others, did lmowingly and
intentionally make one or more extortionate extensions of credit to Jane Doe #2, an
individual whose identity is lmown to the Grand Jury, in violation of Title 18, United States
Code, Sections 892(a) and 2.
elsewhere, the defendant MICHAEL PALMACCI0, together with others, did lmowingly and
intentionally participate in the use of extortionate means (1) to collect and attempt to collect
one or more extensions of credit from Jane Doe #2, and (2) to punish Jane Doe #2 for the
nonrepayment thereof, in violation of Title 18, United States Code, Sections 894(a) and 2.
RACKETEERING ACT NINE

(Illegal Gambling - Sports Betting)
elsewhere, the defendants RONALD GIALLANZO and MICHAEL P ADAVONA, together

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with others, did knowingly and intentionally conduct, finance, manage, supervise, direct and
own all and part of an illegal gambling business, to wit: a gambling business involving sp01is
betting, which operated in violation of the laws of New York State, to wit: New York Penal
Law Sections 225.05, 225.10(1) and 20.00, which involved five or more persons who
conducted, financed, managed, supervised, directed and owned all and part of such business
and which remained in substantially continuous operation for a period in excess of thirty
days and had a gross revenue of at least $2,000 in any single day, in violation of Title 18,
United States Code, Sections 1955 and 2.
RACKETEERING ACT TEN

dates being approximate and inclusive, within the Eastern District of New Yorlc and
elsewhere, the defendant ROBERT PISANI, together with others, did knowingly and
intentionally conduct, finance, manage, supervise, direct and own all and part of an illegal
gambling business, to wit: a gambling business involving spo1is betting, which operated in
violation of the laws of New York State, to wit: New York Penal Law Sections 225. 05,
225.10(1) and 20.00, which involved five or more persons who conducted, financed,
managed, supervised, directed and owned all and part of such business and which remained
in substantially continuous operation for a period in excess of thirty days and had a gross
revenue of at least $2,000 in any single day, in violation of Title 18, United States Code,
Sections 1955 and 2.

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RACKETEERING ACT ELEVEN
(Conspiracy to Murder/Attempted Murder John Doe #5)
constitutes Racketeering Act Eleven:
A. Conspiracy to Murder
45. On or about and between June 1, 2006 and September 18, 2006, both
elsewhere, the defendants RONALD GIALLANZO and MICHAEL PADAVONA, together
with others, did knowingly and intentionally conspire to cause the death of John Doe #5, an
individual whose identity is known to the Grand Jury, in violation of New York Penal Law
Sections 125.25(1) and 105.15.
Eastern District of New York and elsewhere, the defendants RONALD GIALLANZO and
MICHAEL PADAVONA, together with others, did commit and cause to be committed,
among others, the following:
Overt Acts
a. On or about June 28, 2006, the defendant MICHAEL
P ADAVONA provided firearms to co-conspirators for the co-conspirators to use to murder
John Doe #5;
b. On or about June 28, 2006, a co-conspirator shot at John Doe #5
in an attempt to murder him; and

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c. On or about June 28, 2006, the defendant RONALD
GIALLANZO retrieved from a co-conspirator a firearm that was used to attempt to murder
John Doe #5 and discarded the firearm.
B. Attempted Murder
47. On or about June 28, 2006, within the Eastern District of New York
and elsewhere, the defendants RONALD GIALLANZO and MICHAEL PADAVONA,
together with others, with intent to cause the death of John Doe #5, did knowingly and
intentionally attempt to cause the death of John Doe #5, in violation of New York Penal Law
Sections 125.25(1), 110.00 and 20.00.
RACKETEERING ACT TWELVE

(Arson Conspiracy/Arson - John Doe #6)
48. The defendant RONALD GIALLANZO agreed to the commission of
the following acts, either one of which alone constitutes Racketeering Act Twelve:
A. Arson Conspiracy
49. On or about October 5, 2006, within the Eastern District of New York,
the defendant RONALD GIALLANZO, together with others, did knowingly and
intentionally conspire to damage a motor vehicle owned by John Doe #6, an individual
whose identity is known to the Grand Jury, by starting a fire and causing an explosion, in
violation of New York Penal Law Sections 150.10 and 105.10.
Eastern District of New York, the defendant RONALD GIALLANZO, together with others,
did commit and cause to be committed, among others, the following:

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Overt Act
51. On or about October 5, 2006, the defendant RONALD GIALLANZO
identified John Doe #6's motor vehicle to a co-conspirator and ordered the co-conspirator to
set the motor vehicle on fire.
52. On or about October 5, 2006, within the Eastern District of New York,
the defendant RONALD GIALLANZO, together with others, did knowingly and
intentionally damage a motor vehicle owned by John Doe #6 by starting a fire and causing an
explosion, in violation of New York Penal Law Sections 150.10 and 20.00.
RACKETEERING ACT THIRTEEN

(Extortionate Extension and Collection of Credit - John Doe #7)
53. The defendants RONALD GIALLANZO, MICHAEL PALMACCIO,
NICHOLAS FESTA and MICHAEL HINTZE agreed to the commission of the following
acts, either one of which alone constitutes Racketeering Act Thirteen:
54. On or about and between November 1, 2006 and November 11, 2016,
elsewhere, the defendants RONALD GIALLANZO, MICHAEL PALMACCIO,
NICHOLAS FESTA and MICHAEL HINTZE, together with others, did knowingly and
intentionally make one or more extortionate extensions of credit to John Doe #7, an
individual whose identity is known to the Grand Jury, in violation of Title 18, United States

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55. On or about and between November 1, 2006 and November 11, 2016,
elsewhere, the defendants RONALD GIALLANZO, MICHAEL PALMACCIO,
NICHOLAS FESTA and MICHAEL HINTZE, together with others, did knowingly and
one or more extensions of credit from John Doe #7, and (2) to punish John Doe #7 for the
RACKETEERING ACT FOURTEEN

56. The defendant NICHOLAS FESTA agreed to the commission of the
following acts, either one of which alone constitutes Racketeering Act Fourteen:
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RACKETEERING ACT FIFTEEN

elsewhere, the defendant MICHAEL PALMACCIO, together with others, did lmowingly and
intentionally conduct, finance, manage, supervise, direct and own all and part of an illegal
gambling business, to wit: a gambling business involving sports betting, which operated in
violation of the laws of New York State, to wit: New York Penal Law Sections 225.05,
225.10(1) and 20.00, which involved five or more persons who conducted, financed,
managed, supervised, directed and owned all and part of such business and which remained
in substantially continuous operation for a period in excess of thirty days and had a gross
revenue of at least $2,000 in any single day, in violation of Title 18, United States Code,
Sections 1955 and 2.
RACKETEERING ACT SIXTEEN

following acts, either one of which alone constitutes Racketeering Act Sixteen:
61. On or about and between January 1, 2007 and May 30, 2012, both dates
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defendant NICHOLAS FESTA, together with others, did knowingly and intentionally make
one or more extortionate extensions of credit to John Doe #9, an individual whose identity is
known to the Grand Jury, in violation of Title 18, United States Code, Sections 892(a) and 2.
defendant NICHOLAS FESTA, together with others, did knowingly and intentionally
participate in the use of extortionate means (1) to collect and attempt to collect one or more
extensions of credit from John Doe #9, and (2) to punish John Doe #9 for the nonrepayment
thereof, in violation of Title 18, United States Code, Sections 894(a) and 2.
RACKETEERING ACT SEVENTEEN

63. The defendant ROBERT PISANI agreed to the commission of the
following acts, either one of which alone constitutes Racketeering Act Seventeen:
64. On or about and between January 1, 2008 and March 13, 2013, both

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RACKETEERING ACT EIGHTEEN

(Extortionate Extension and Collection of Credit - John Doe # 11)
the following acts, either one of which alone constitutes Racketeering Act Eighteen:
67. On or about and between September 1, 2009 and November 1, 2010,
elsewhere, the defendant MICHAEL PALMACCI0, together with others, did lmowingly and
intentionally make one or more extortionate extensions of credit to John Doe # 11, an
68. On or about and between September 1, 2009 and November 1, 2010,
elsewhere, the defendant MICHAEL PALMACCIO, together with others, did lmowingly and
intentionally participate in the use of extortionate means ( 1) to collect and attempt to collect
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RACKETEERING ACT NINETEEN


I
following acts, either one of which alone constitutes Racketeering Act Nineteen:
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RACKETEERING ACT TWENTY
(Robbery Conspiracy/Robbery- John Doe #13)
72. The defendants MICHAEL PADAVONA and MICHAEL
PALMACCIO agreed to the commission of the following acts, either one of which alone
constitutes Racketeering Act Twenty:
A. Robbery Conspiracy
73. On or about and between December 15, 2011 and December 23, 2011,
elsewhere, the defendants MICHAEL PADAVONA and MICHAEL PALMACCI0, together
with others, did knowingly and intentionally conspire to forcibly steal property, to wit:
money from John Doe #13, an individual whose identity is known to the Grand Jury, while
aided by another person actually present, in violation of New York Penal Law Sections
160.10 and 105.10.
Eastern District of New York and elsewhere, the MICHAEL PADAVONA and MICHAEL
PALMACCI 0, together with others, did commit and cause to be committed, among others,
the following:
Overt Acts
a. On or about December 15, 2011, the defendants MICHAEL
PADAVONA and MICHAEL PALMACCIO told co-conspirators to rob John Doe #13; and
b. On or about December 23, 2011, co-conspirators entered the
home of John Doe #13 and robbed jewelry from John Doe #13's home.
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B. Robbery
75. On or about December 23, 2011, within the Eastern District of New
York and elsewhere, the defendants MICHAEL P ADAVONA and MICHAEL
PALMACCIO, together with others, did forcibly steal property, to wit: jewelry from John
Doe # 13, in violation of New York Penal Law Sections 160. 05 and 20. 00.
RACKETEERING ACT TWENTY-ONE

(Extortionate Collection of Credit- John Doe #14)
76. On or about and between January 1, 2012 and July 7, 2014, both dates
defendant CHRISTOPHER BOOTHBY, together with others, did knowingly and
one or more extensions of credit from John Doe #14, an individual whose identity is lmown
to the Grand Jury, and (2) to punish John Doe #14 for the nonrepayment thereof, in violation
RACKETEERING ACT TWENTY-TWO
(Extortionate Extension and Collection of Credit Conspiracy)
77. The defendants MICHAEL P ADAVONA, EVAN GREENBERG and
ROBERT TANICO agreed to the commission of the following acts, either one of which
alone constitutes Racketeering Act Twenty-Two:
A. Extortionate Extension of Credit Conspiracy
78. On or about and between November 1, 2012 and May 30, 2016, both
elsewhere, the defendants MICHAEL P ADAVONA, EVAN GREENBERG and ROBERT

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TAN1CO, together with others, did knowingly and intentionally conspire to make one or
more extortionate extensions of credit, in violation of Title 18, United States Code, Section
892(a).
B. Extortionate Collection of Credit Conspiracy
elsewhere, the defendants MICHAEL PADAVONA, EVAN GREENBERG and ROBERT
TAN1CO, together with others, did knowingly and intentionally conspire to paiiicipate in the
use of exto1iionate means (1) to collect and attempt to collect one or more extensions of
credit, and (2) to punish one or more persons for the nonrepayment thereof, in violation of
Title 18, United States Code, Section 894(a).
RACKETEERING ACT TWENTY-THREE

constitutes Racketeering Act Twenty-Three:
A. Ext01iionate Extension of Credit
with others, did knowingly and intentionally make one or more extortionate extensions of
credit to John Doe #15, an individual whose identity is known to the Grand Jury, in violation

27
with others, did knowingly and intentionally participate in the use of extortionate means
(1) to collect and attempt to collect one or more extensions of credit from John Doe #15, and
(2) to punish John Doe #15 for the nonrepayment thereof, in violation of Title 18, United
RACKETEERING ACT TWENTY-FOUR
83. The defendant RONALD GIALLANZO agreed to the commission of
the following acts, either one of which alone constitutes Racketeering Act Twenty-Four:
84. On or about and between March 1, 2013 and May 30, 2013, both dates
defendant RONALD GIALLANZO, together with others, did lmowingly and intentionally
make one or more extortionate extensions of credit to John Doe #16, an individual whose
identity is lmown to the Grand Jury, in violation of Title 18, United States Code, Sections
892(a) and 2.
defendant RONALD GIALLANZO, together with others, did knowingly and intentionally
28
participate in the use of extortionate means (1) to collect and attempt to collect one or more
extensions of credit from John Doe #16, and (2) to punish John Doe #16 for the
RACKETEERING ACT TWENTY-FIVE

86. On or about and between August 1, 2013 and April 30, 2016, both
elsewhere, the defendants RONALD GIALLANZO and CHRISTOPHER BOOTHBY,
together with others, did knowingly and intentionally conduct, finance, manage, supervise,
direct and own all and part of an illegal gambling business, to wit: a gambling business
involving sports betting, which operated in violation of the laws of New York State, to wit:
New York Penal Law Sections 225.05 and 20.00, which involved five or more persons who
conducted, financed, managed, supervised, directed and owned all and part of such business
and which remained in substantially continuous operation for a period in excess of thirty
days and had a gross revenue of at least $2,000 in any single day, in violation of Title 18,
United States Code, Sections 1955 and 2.
RACKETEERING ACT TWENTY-SIX

87. The defendant CHRISTOPHER BOOTHBY agreed to the commission
of the following acts, either one of which alone constitutes Racketeering Act Twenty-Six:
88. On or about and between January 1, 2014 and April 30, 2016, both
29
elsewhere, the defendant CHRISTOPHER BOOTHBY, together with others, did knowingly
and intentionally make one or more extortionate extensions of credit to John Doe #17, an
individual whose identity is known to the Grand Jmy, in violation of Title 18, United States
elsewhere, the defendant CHRISTOPHER BOOTHBY, together with others, did knowingly
and intentionally participate in the use of extortionate means (1) to collect and attempt to
collect one or more extensions of credit from John Doe #17, and (2) to punish John Doe #17
for the nonrepayment thereof, in violation of Title 18, United States Code, Sections 894(a)
and 2.
RACKETEERING ACT TWENTY-SEVEN

constitutes Racketeering Act Twenty-Seven:
91. On or about and between March 1, 2014 and April 30, 2016, both dates
knowingly and intentionally make one or more extortionate extensions of credit to John Doe
#17, in violation of Title 18, United States Code, Sections 892(a) and 2.
30
B. Ext01iionate Collection of Credit
attempt to collect one or more extensions of credit from John Doe #17, and (2) to punish
John Doe #17 for the nonrepayment thereof, in violation of Title 18, United States Code,
Sections 894(a) and 2.
RACKETEERING ACT TWENTY-EIGHT
(Obstruction of Justice Conspiracy/Obstruction of Justice)
93. The defendants MICHAEL PADAVONA and ROBERT TANICO
agreed to the commission of the following acts, either one of which alone constitutes
Racketeering Act Twenty-Eight:
A. Obstruction of Justice Conspiracy
94. On or about and between April 1, 2014 and April 2, 2014, both dates
defendants MICHAEL PADAVONA and ROBERT TANI CO, together with others, did
knowingly, intentionally and corruptly conspire to obstruct, influence and impede an official
proceeding, to wit: a proceeding before a Federal grand jury in the Eastern District of New
York, ~ontra1y to Title 18, United States Code, Section 1512(c)(2), in violation of Title 18,
United States Code, Section 1512(k).

31
B. Obstruction of Justice Attempt
defendants MICHAEL PADAVONA and ROBERT TANICO, together with others, did
knowingly, intentionally and corruptly attempt to obstruct, influence and impede an official
proceeding, to wit: a proceeding before a Federal grand jury in the Eastern District of New
York, in violation of Title 18, United States Code, Sections 1512(c)(2) and 2.
RACKETEERING ACT TWENTY-NINE

(Extortionate Collections of Credit - John Doe # 18)
96. The defendants named below agreed to the commission of the
following acts, any one of which alone constitutes Racketeering Act Twenty-Nine:
97. On or about the dates identified in the table below, within the Eastern
District of New York and elsewhere, the defendants identified in the table below, together
with others, did knowingly and intentionally participate in the use of extortionate means to
collect and attempt to collect one or more extensions of credit from John Doe#18, an
individual whose identity is known to the Grand Jmy, in violation of Title 18, United States
Code, Sections 894(a)(l) and 2.
RACKETEERING DATE DEFENDANTS

SUB-ACT
A May 19, 2014 MICHAEL PADAVONA and
EVAN GREENBERG
B June 18, 2014 MICHAEL PADAVONA and

EVAN GREENBERG
32
C July 15, 2014 MICHAELPADAVONAand

EVAN GREENBERG
D November 24, 2014 MICHAEL PADAVONA and

ROBERT TANICO
E May 28, 2015 MICHAEL PADAVONA and

ROBERT TANICO
F April 13, 2016 MICHAELPADAVONA
G May 16, 2016 MICHAELPADAVONA
RACKETEERING ACT THIRTY
98. The defendant RICHARD HECK agreed to the commission of the
following acts, either one of which alone constitutes Racketeering Act Thirty:
99. On or about and between August 1, 2014 and January 15, 2016, both
elsewhere, the defendant RICHARD HECK, together with others, did knowingly and
intentionally make one or more extortionate extensions of credit to John Doe #15, in
violation of Title 18, United States Code, Sections 892(a) and 2.
elsewhere, the defendant RICHARD HECK, together with others, did knowingly and
33
(Title 18, United States Code, Sections 1962(d), 1963 and 3551 et seq.)
COUNT TWO
(Financing Extortionate Extensions of Credit)
York and elsewhere, the defendant RONALD GIALLANZO, also known as "Ronnie G,"
together with others, did knowingly and intentionally advance money and property, as a gift,
a loan and an investment, pursuant to a partnership and profit-sharing agreement and
otherwise, to one or more persons, with reasonable grounds to believe that it was the
intention of those persons to use the money and property so advanced directly and indirectly
for the purpose of making one or more extortionate extensions of credit.
(Title 18, United States Code, Sections 893, 2 and 3551 et~-)
COUNT THREE
(Extortionate Extension of Credit Conspiracy)
MICHAEL PADAVONA, also known as "Mike," MICHAEL PALMACCI 0, also known as
"Mike," NICHOLAS FESTA, also known as "Pudgie," RICHARD HECK, also known as
34
"Richie," and MICHAEL HINTZE, also known as "Mike," together with others, did
knowingly and intentionally conspire to make one or more extortionate extensions of credit.
(Title 18, United States Code, Sections 892(a) and 3551 et seq.)
COUNTFOUR
(Extortionate Collection of Credit Conspiracy)
MICHAEL PADAVONA, also known as "Mike," MICHAEL PALMACCIO, also known as
"Mike," NICHOLAS FESTA, also known as "Pudgie," RICHARD HECK, also known as
"Richie," and MICHAEL HINTZE, also known as "Mike," together with others, did
lmowingly and intentionally conspire to participate in the use of extortionate means (1) to
collect and attempt to collect one or more extensions of credit, and (2) to punish one or more
persons for the nonrepayment thereof.
(Title 18, United States Code, Sections 894(a) and 3551 et~.)
COUNT FIVE
(Extortionate Extension of Credit Conspiracy)
elsewhere, the defendants MICHAEL PADAVONA, also lmown as "Mike," EVAN
GREENBERG, also lmown as "The Jew," and ROBERT TANICO, also lmown as "Chippy"
35
and "Chip," together with others, did knowingly and intentionally conspire to make one or
more extortionate extensions of credit.
COUNT SIX
(Extortionate Collection of Credit Conspiracy)
elsewhere, the defendants MICHAEL PADAVONA, also known as "Mike," EVAN
GREENBERG, also known as "The Jew," and ROBERT TANICO, also known as "Chippy"
and Chip," together with others, did knowingly and intentionally conspire to participate in
the use of extortionate means (1) to collect and attempt to collect one or more extensions of
credit, and (2) to punish one or more persons for the nonrepayment thereof.
COUNT SEVEN
(Extortionate Extension of Credit-John Doe #4)
elsewhere, the defendant MICHAEL PALMACCIO, also known as "Mike," together with
others, did knowingly and intentionally make one or more extortionate extensions of credit to
JohnDoe#4.
(Title 18, United States Code, Sections 892(a), 2 and 3551 et~.)
36
COUNT EIGHT
(Extortionate Collection of Credit - John Doe #4)
elsewhere, the defendant MICHAEL PALMACCI0, also known as "Mike," together with
others, did knowingly and intentionally participate in the use of extortionate means (1) to
collect and attempt to collect one or more extensions of credit from John Doe #4, and (2) to
punish John Doe #4 for the nonrepayment thereof.
(Title 18, United States Code, Sections 894(a), 2 and 3551 et seq.)
COUNT NINE
(Extortionate Extension of Credit - John Doe #9)
defendant NICHOLAS FESTA, also known as "Pudgie," together with others, did knowingly
and intentionally make one or more extortionate extensions of credit to John Doe #9.
COUNT TEN
(Extortionate Collection of Credit - John Doe #9)
defendant NICHOLAS FESTA, also known as "Pudgie," together with others, did knowingly
and intentionally participate in the use of extortionate means (1) to collect and attempt to
37
collect one or more extensions of credit from John Doe #9, and (2) to punish John Doe #9 for
the nonrepayment thereof.
COUNT ELEVEN
(Extortionate Extension of Credit - John Doe #10)
elsewhere, the defendant ROBERT PISANI, also known as "Rob," together with others, did
#10.
COUNT TWELVE
(Extortionate Collection of Credit - John Doe # 10)
elsewhere, the defendant ROBERT PISANI, also known as "Rob," together with others, did
John Doe # 10 for the nonrepayment thereof.
COUNT TIDRTEEN
(Extortionate Extension of Credit- John Doe #12)
38
elsewhere, the defendant NICHOLAS FESTA, also known as "Pudgie," together with others,
did knowingly and intentionally make one or more extortionate extensions of credit to John
Doe #12.
COUNT FOURTEEN
(Extortionate Collection of Credit John Doe #12)
elsewhere, the defendant NICHOLAS FESTA, also known as "Pudgie," together with others,
did knowingly and intentionally participate in the use of extortionate means (1) to collect and
John Doe #12 for the nonrepayment thereof.
COUNT FIFTEEN
114. On or about and between January 1, 2012 and July 7, 2014, both dates
defendant CHRISTOPHER BOOTHBY, also known as "Bald Chris," together with others,
did knowingly and intentionally participate in the use of extortionate means (1) to collect and
John Doe # 14 for the nonrepayment thereof.
39
COUNT SIXTEEN
(Extortionate Extension of Credit - John Doe # 15)
elsewhere, the defendants RONALD GIALLANZO, also known as "Ronnie G," and
MICHAEL PADAVONA, also known as "Mike," together with others, did knowingly and
intentionally make one or more exto1iionate extensions of credit to John Doe # 15.
COUNT SEVENTEEN
(Extortionate Collection of Credit John Doe #15)
intentionally paiiicipate in the use of extortionate means (1) to collect and attempt to collect
nonrepayment thereof.
(Title 18, United States Code, Sections 894(a), 2 and 3551 et~-)
COUNT EIGHTEEN
defendant RONALD GIALLANZO, also known as "Ronnie G," together with others, did
40
#16.
(Title 18, United States Code, Sections 892(a), 2 and 3551 et film.)
COUNT NINETEEN
defendant RONALD GIALLANZO, also known as "Ronnie G," together with others, did
John Doe #16 for the nonrepayment thereof.
COUNT TWENTY
elsewhere, the defendant CHRISTOPHER BOOTHBY, also known as "Bald Chris,"
together with others, did knowingly and intentionally make one or more extortionate
extensions of credit to John Doe # 17.
COUNT TWENTY-ONE
120. On or about and between Januaiy 1, 2014 and April 30, 2016, both
dates being approximate and inclusive, within the Eastern District of New Yorlc and
41
elsewhere, the defendant CHRISTOPHER BOOTHBY, also known as "Bald Chris,"
together with others, did knowingly and intentionally participate in the use of extortionate
means (1) to collect and attempt to collect one or more extensions of credit from John Doe
#17, and (2) to punish John Doe #17 for the nonrepayment thereof.
COUNT TWENTY-TWO
defendants RONALD GIALLANZO, also known as "Ronnie," and MICHAEL
PADAVONA, also known as "Mike," together with others, did knowingly and intentionally
make one or more extortionate extensions of credit to John Doe #17.
COUNT TWENTY-THREE
122. On or about and between March 1, 2014 and April 30, 2016, both
elsewhere, the defendants RONALD GIALLANZO, also known as "Ronnie," and
42
nonrepayment thereof.
COUNTS TWENTY-FOUR THROUGH THIRTY

(Ext01iionate Collections of Credit- John Doe #18)
123. On or about the dates identified in the table below, within the Eastern
District of New York and elsewhere, the defendants identified in the table below, together
with others, did knowingly and intentionally participate in the use of extortionate means to
collect and attempt to collect one or more extensions of credit from John Doe #18:
COUNT DATE DEFENDANTS
TWENTY-FOUR May 19, 2014 MICHAEL PADAVONA and

EVAN GREENBERG
TWENTY-FIVE June 18, 2014 MICHAEL PADAVONA and
EVAN GREENBERG
TWENTY-SIX July 15, 2014 MICHAELPADAVONAand
EVAN GREENBERG
TWENTY-SEVEN November 24, 2014 MICHAELPADAVONAand
ROBERT TANICO
TWENTY-EIGHT May 28, 2015 MICHAEL PADAVONA and
ROBERT TANICO
TWENTY-NINE April 13, 2016 MICHAEL PADAVONA
THIRTY May 16, 2016 MICHAEL PADAVONA
(Title 18, United States Code, Sections 894(a)(l), 2 and 3551 et seq.)
COUNT THIRTY-ONE
43
elsewhere, the defendant RICHARD HECK, also known as "Richie," together with others,
did lmowingly and intentionally make one or more extortionate extensions of credit to John
Doe #15.
COUNT THIRTY-TWO
(Extortionate Collection of Credit- John Doe #15)
dates being approximate and inclusive, within the Eastern District ofNew York and
elsewhere, the defendant RICHARD HECK, also lmown as "Richie," together with others,
did lmowingly and intentionally participate in the use of extmiionate means (1) to collect and
John Doe # 15 for the nonrepayrnent thereof.
COUNT THIRTY-THREE
elsewhere, the defendant ROBERT PISANI, also lmown as "Rob," together with others, did
lmowingly and intentionally conduct, finance, manage, supervise, direct and own all and part
of an illegal gambling business, to wit: a gambling business involving sports betting, which
operated in violation of the laws of New York State, to wit: New Yorlc Penal Law Sections
225.05 and 20.00, which involved five or more persons who conducted, financed, managed,
supervised, directed and owned all and part of such business and which remained in
44
substantially continuous operation for a period in excess of thirty days and had a gross
revenue of at least $2,000 in any single day.
(Title 18, United States Code, Sections 1955, 2 and 3551 et seq.)
COUNT THIRTY-FOUR
(Illegal Gambling - Sp01is Betting)
127. On or about and between August 1, 2013 and April 30, 2016, both
CHRISTOPHER BOOTHBY, also known as "Bald Chris," together with others, did
knowingly and intentionally conduct, finance, manage, supervise, direct and own all and part
of an illegal gambling business, to wit: a gambling business involving sp01is betting, which
operated in violation of the laws of New York State, to wit: New York Penal Law Sections
225.05 and 20.00, which involved five or more persons who conducted, financed, managed,
supervised, directed and owned all and part of such business and which remained in
substantially continuous operation for a period in excess of thirty days and had a gross
revenue of at least $2,000 in any single day.
(Title 18, United States Code, Sections 1955, 2 and 3551 et~.)
COUNT THIRTY-FIVE
(Obstruction of Justice Conspiracy)
defendants MICHAEL PADAVONA, also known as "Mike," and ROBERT TANICO, also
known as "Chippy" and "Chip," together with others, did knowingly, intentionally and
45
corruptly conspire to obstruct, influence and impede an official proceeding, to wit: a
proceeding before a Federal grand jury in the Eastern District of New York, contrary to Title
18, United States Code, Section 1512(c)(2).
(Title 18, United States Code, Sections 1512(k) and 3551 et~.)
COUNT THRITY-SIX
(Obstruction of Justice Attempt)
defendants MICHAEL PADAVONA, also known as "Mike," and ROBERT TANICO, also
known as "Chippy" and "Chip," together with others, did knowingly, intentionally and
corruptly attempt to obstruct, influence and impede an official proceeding, to wit: a
proceeding before a Federal grandjmy in the Eastern District of New York.
(Title 18, United States Code, Sections 1512(c)(2), 2 and 3551 et~.)
COUNT THIRTY-SEVEN
(Perjury)
130. On or about April 2, 2014, within the Eastern District ofNew York, the
defendant ROBERT TANICO, also known as "Chippy" and "Chip," while under oath in a
proceeding before a grand jmy of the United States, to wit: a Federal grand jmy in the
Eastern District of New York, did knowingly and intentionally make one or more false
material declarations, including the underlined testimony set forth below:
Q: Have you spoken to [Michael Padavona] since the last two weeks?
A: I don't believe so, no.
Q: That's a no?
46
A: Yes.
Q: When you received the subpoena in this case, who did you speak to the
subpoena about?
A: Joe.
Q: Did you tell anyone else about it?
A: My wife, my mother, my sister, that's about it.
Q: Anyone else you can think of?
A: No.
Q: Did you tell Mike Padavon[a] about it?
A: No.
Q: Other than your wife, your sister; which sister?
A: I only have one sister, Lee Anne.
Q: Sony. And your lawyer, Joe Mure?
A: My mother.
Q: You haven't spoken with anyone else about the fact you were
subpoenaed to be here today?
A: No.
(Transcript, Page 17, lines 2 through 21)
131. The testimony identified above by the defendant ROBERT TANICO,
also known as "Chippy" and "Chip," as he then and there well knew and believed, was false
in that on or about April 1, 2014, during a call intercepted pursuant to court-authorized
wiretapping, the defendant ROBERT TANICO, also known as "Chippy" and "Chip," told
47
MICHAEL PADAVONA, also lmown as "Mike," a soldier in the Bonanno crime family,
that TANICO had been subpoenaed to testify before a grandjmy.
(Title 18, United States Code, Sections 1623 and 3551 et~.)
CRIMINAL FORFEITURE ALLEGATION

AS TO COUNT ONE
132. The United States hereby gives notice to the defendants that, upon their
conviction of the offense charged in Count One, the government will seek forfeiture in
accordance with Title 18, United States Code, Section 1963(a), which requires any person
convicted of such offense to forfeit: (a) any interest the person acquired or maintained in
violation of Title 18, United States Code, Section 1962; (b) any interest in, security of, claim
against, or property or contractual right of any kind affording a source of influence over any
enterprise which the person has established, operated, controlled, conducted, or participated
in the conduct of, in violation of Title 18, United States Code, Section 1962, and (c) any
property constituting, or derived from, any proceeds which the person obtained, directly or
indirectly, from racketeering activity or unlawful debt collection in violation of Title 18,
United States Code, Section 1962, including but not limited to: (a) the sum of at least
approximately twenty-six million twenty-seven thousand eight hundred eighty-eight dollars
and sixty-three cents ($26,027,088.63); (b) all right, title and interest in the real property and
premises located at 164-04 86th Street, Howard Beach, New York; (b) all right, title and
interest in the real property and premises located at 159-28 85th Street, Howard Beach, New
York; (c) all right, title and interest in the real property and premises located at 163-27 91 st
Street, Howard Beach, New York; (d) all right, title and interest in the real property and
premises located at 500 Pierce Street, Oceanside, New York; and (e) all right, title and
48
interest in the real property and premises located at 925 Cross Bay Boulevard, Broad
Channel, New York.
133. If any of the above-described forfeitable prope1iy, as a result of any act
or omission of the defendants:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be
divided without difficulty;
it is the intent of the United States, pursuant to Title 18, United States Code, Section
1963(m), to seek forfeiture of any other property of the defendants up to the value of the
forfeitable property described in this forfeiture allegation.
(Title 18, United States Code, Sections 1963(a) and 1963(m))
CRIMINAL FORFEITURE ALLEGATION AS TO

COUNTS TWO THROUGH THIRTY-TWO, THIRTY-FIVE AND THIRTY-SIX
134. The United States hereby gives notice to the defendants charged in
Counts Two through Thirty-Two, Thi1iy-Five and Thirty-Six that, upon their conviction of
any such offenses, the government will seek forfeiture in accordance with Title 18, United
States Code, Section 981(a)(l)(C) and Title 28, United States Code, Section 2461(c), which
require any person convicted of such offenses to forfeit any property, real or personal,
constituting, or derived from, proceeds obtained directly or indirectly as a result of such
offenses, including but not limited to: (a) the sum of at least approximately twenty-six
49
million twenty-seven thousand eight hundred eighty-eight dollars and sixty-three cents
($26,027,088.63); (b) all right, title and interest in the real propetiy and premises located at
164-04 86th Street, Howard Beach, New York; (b) all right, title and interest in the real
property and premises located at 159-28 85th Street, Howard Beach, New York; (c) all right,
title and interest in the real property and premises located at 163-27 91st Street, Howard
Beach, New York; ( d) all right, title and interest in the real property and premises located at
500 Pierce Street, Oceanside, New York; and (e) all right, title and interest in the real
property and premises located at 925 Cross Bay Boulevard, Broad Channel, New York.
135. If any of the above-described forfeitable property, as a result of any act
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p ),
to seek forfeiture of any other property of the defendants up to the value of the forfeitable
property described in this forfeiture allegation.
(Title 18, United States Code, Section 98l(a)(l)(C); Title 21, United States
Code, Section 853(p); Title 28, United States Code, Section 2461(c))
50
CRIMINAL FORFEITURE ALLEGATION AS TO
COUNTS THIRTY-THREE AND THIRTY-FOUR
136. The United States hereby gives notice to the defendants charged in
Counts Thirty-Three and Thirty-Four that, upon their conviction of either such offenses, the
government will seek forfeiture in accordance with (a) Title 18, United States Code, Section
98l(a)(l)(C) and Title 28, United States Code, Section 246l(c), which require any person
convicted of such offenses to forfeit any property constituting, or derived from, proceeds
obtained directly or indirectly as a result of such offenses; and (b) Title 18, United States
Code, Section 1955(d), which provides for the forfeiture of any property, including money,
used in violation of Title 18, United States Code, Section 1955.
137. If any of the above-described forfeitable property, as a result of any act

51
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p),
to seek forfeiture of any other property of the defendants up to the value of the forfeitable
property described in this forfeiture allegation.
(Title 18, United States Code, Sections 98l(a)(l)(C) and 1955(d); Title 21,
United States Code, Section 853(p); Title 28, United States Code, Section 2461(c))
ACTING UNITED STATES ATTORNEY

EASTERN DISTRICT OF NEW YORK

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AL:NMA:LKG/KDE

UNITED STATES DISTRICT COURT

(T. 1 , U.S.C., 892(a), 893, 894(a),

MICHAEL PALMACCIO, 2461(c))

also known as "Mike,"

THE GRAND JURY CHARGES:

At all times relevant to this Indictment, unless otherwise indicated:

1. The Bonanno organized crime family of La Cosa Nostra, including its

leaders, members and associates (the "Bonanno family"), constituted an "enterprise," as

Bonanno family constituted an ongoing organization, whose members functioned as a

2. The Bonanno family operated through groups of individuals headed by

"captains," who were also referred to as "skippers," "caporegimes" and "capodecinas."

"good fellows" and "buttons," as well as associates of the Bonanno family.

3. Each captain was responsible for supervising the criminal activities of

4. Above the captains were the three highest-ranking members of the

members and associates of the Bonanno family, including murder.

sometimes refe1red to collectively as the "administration," supervised, supported, protected

earnings of each crew.

6. The Bonanno family was part of an international criminal organization

removed from membership within the commission.

7. From time to time, the Bonanno family would propose a list of

Bonanno family, its members or associates.

The Purposes, Methods and Means of the Enterprise

8. The principal purpose of the Bonanno family was to generate money

9. Although the primary purpose of the Bonanno family was to generate

crimes, acts of violence, including murder, assault and arson.

location of proceeds of those activities. That conduct included a commitment to murdering

as potential witnesses against members and associates of the enterprise.

11. Members and associates of the Bonanno family often coordinated

street-level criminal activity, such as drng trafficking, illegal gambling, loansharking,

12. At all times relevant to this Indictment, the defendant RONALD

13. At various times relevant to this Indictment, the defendant MICHAEL

PADAVONA, also known as "Mike," MICHAEL PALMACCIO, also known as "Mike,"

14. At various times relevant to this Indictment, the defendants

CHRISTOPHER BOOTHBY, also known as "Bald Chris," EVAN GREENBERG, also

known as "Chippy" and "Chip," were associates in the Bonanno family.

15. The allegations in paragraphs one through 14 are realleged and

incorporated as if fully set forth in this paragraph.

MICHAEL PADAVONA, also known as "Mike," MICHAEL PALMACCI0, also known as

"Mike," NICHOLAS FESTA, also known as "Pudgie," CHRISTOPHER BOOTHBY, also

RACKETEERING ACT ONE

(Kidnapping Conspiracy/Kidnapping/Robbery Conspiracy/

Attempted Robbery-John Doe #1)

17. The defendant CHRISTOHER BOOTHBY agreed to the commission

135.20 and 105.10.

a. On or about February 2, 1998, the defendant CHRISTOPHER

b. On or about February 2, 1998, the defendant CHRISTOPHER

BOOTHBY and a co-conspirator tied up John Doe #1.

160.10 and 105.10.

a. On or about February 2, 1998, the defendant CHRISTOPHER

b. On or about February 2, 1998, the defendant CHRISTOPHER

BOOTHBY and a co-conspirator tied up John Doe #1.

of New York Penal Law Sections 160.05, 110.05 and 20.00.

RACKETEERING ACT TWO

(Extortionate Extension and Collection of Credit Conspiracy)

24. The defendants RONALD GIALLANZO, MICHAEL PADAVONA,

MICHAEL PALMACCIO, NICHOLAS FESTA, RICHARD HECK and MICHAEL

constitutes Racketeering Act Two:

A. Extortionate Extension of Credit Conspiracy

York and elsewhere, the defendants RONALD GIALLANZO, MICHAEL PADAVONA,

MICHAEL PALMACCIO, NICHOLAS FESTA, RICHARD HECK and MICHAEL

B. Extortionate Collection of Credit Conspiracy

York and elsewhere, the defendants RONALD GIALLANZO, MICHAEL PADAVONA,

MICHAEL PALMACCIO, NICHOLAS FESTA, RICHARD HECK and MICHAEL